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District unveils revised harassment, discrimination and Title IX procedures, adds online intake and splits investigative roles
Summary
District staff presented a package of AC and ACR policy and regulation updates triggered by federal Title IX changes and recent state law; proposals include splitting student and staff investigative roles, an online intake form, mandated training for investigators and a single complaint form for civil-rights reports.
Thompson School District R-2J administrators presented a multi-part package of policy updates on Nov. 5 to address changes in federal Title IX regulation and Colorado law on harassment and bullying, propose operational changes to investigative roles, and introduce a centralized online intake for civil‑rights complaints.
Valerie Laura Black, director of human resources, and compliance coordinator Colin Nyeke told the board the district combined multiple discrimination and harassment procedures into a clearer set of documents (AC and related regulations ACR‑1, ACR‑2 and ACR‑3) in response to changes in Title IX regulations and a 2023 Colorado law addressing bullying. "Those regulations were enjoined January 2025," Black said of recent federal rule activity, and the district is aligning local policies accordingly.
Key operational proposals include splitting complaint intake and investigations so that student‑to‑student complaints are addressed by the student compliance team while staff‑related complaints are handled by HR. Presenters said the split responded to workload concerns and legal advice; the district will continue to build administrator capacity but does not intend to routinely delegate full investigations to building administrators.
The package also includes a single, districtwide complaint form and a ready‑to‑launch online intake built with technology staff support; Black said the online form "allows people to report directly to us" and will route reports confidentially to the appropriate coordinator. The administration emphasized training requirements for investigators and decision‑makers and said it has scheduled initial administrator training to match the new procedures.
Board members asked whether policy language that permits delegation to building administrators might conflict with the district's intent to keep investigations centralized. Presenters said the delegation language remains to preserve legal flexibility, but that the district's plan is to keep investigations with trained central staff and only use delegation with intensive oversight when necessary. The board also discussed the legal requirement to identify Title IX coordinators prominently; presenters confirmed policy must list coordinator contact information, and that the administration will centralize and maintain those references on the district website to avoid frequent policy edits.
The board probed appeal rights and consistency with the district's equity policy; staff said narrow federal appeal standards exist for Title IX and that other remedies remain available (for example, board-level complaint processes under policies KE/KE‑R or state complaint avenues). Administrators noted an omission that staff will correct: the complaint exhibits should explicitly make clear that members of the public may file civil‑rights complaints (for Title VI, ADA, Title IX, etc.) and that staff will update ACE/ACE‑R language accordingly.
No policy votes were taken during the study session; the administration asked trustees to forward specific wording suggestions before the next reading and said it will bring the draft back for approval at an upcoming regular meeting.
